Blog

UK: CbC Reporting Regulations Coming Into Force Soon

The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 were recently issued. These rules are coming into force on March 18, 2016. Reporting applies to any taxation year commencing after December 31st, 2015. The...
Posted by DRTP On 16 March 2016

“Behaviour which was Considered both Legal and Normal in the Past will no Longer be Accepted”

These were (some) of the words of OECD Secretary-General Angel Gurría included in the OECD invitation to every country and jurisdiction "interested" to join the global efforts to close international "tax loopholes", as it was issued...
Posted by DRTP On 10 March 2016

Canada-European Union: Comprehensive Economic and Trade Agreement (CETA)

Recently, Global Affairs Canada indicated that: ["o]n February 29, 2016, Canada’s Minister of International Trade, Chrystia Freeland, and the European Union’s Commissioner for Trade Cecilia Malmström announced the completion of the legal review of CETA....
Posted by DRTP On 3 March 2016

Cross-Border Transactions and Transfer Pricing – Part III

Read the third installment of this series titled Cross-border Transactions and Transfer Pricing. A Case Study: Sales Operations in Canada – Part III available through the Canadian German Chamber of Industry and Commerce Newsletter (February 2016): http://kanada.ahk.de/fileadmin/ahk_kanada/Newsletter/2016/02._February_2016/DRTP-Transfer-Pricing-Case-Study-Part_III-CGCIC-final.pdf The...
Posted by DRTP On 2 March 2016

OECD Proposes Changes to Model Tax Convention: Treaty Residence of Pension Funds

The OECD explains: "This discussion draft includes draft changes to Articles 3 and 4 of the OECD Model Tax Convention, and to the Commentary on these Articles, that will ensure that a pension fund is...
Posted by DRTP On 1 March 2016